Final regulations from the U.S. IRS and Treasury on Allocation of Creditable Foreign Taxes (T.D. 9871) has been published in the Federal Register. The regulations are effective on 24 July 2019 and adopt, with some changes, proposed regs (REG-100861-15) and remove temporary regulations (T.D. 9748), which were issued in 2016.
---
This document contains final regulations with respect to a provision of the Internal Revenue Code (Code) that addresses the allocation by a partnership of foreign i…